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Case TitleAGRAMA v.INTERNAL REVENUE SERVICE
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2016cv00751
Date Filed2016-04-22
Date Closed2017-10-23
JudgeJudge Rosemary M. Collyer
PlaintiffJEHAN AGRAMA
Case DescriptionJehan Agrama submitted a FOIA request to the IRS for records concerning why the agency had decided Agrama was required to file certain forms. The agency located 86 pages and disclosed three pages. The agency withheld the remainder of the records under Exemption 3 (other statutes), Exemption 7(A) (interference with ongoing investigation or proceeding), and Exemption 7(C) (invasion of privacy concerning law enforcement records). Agrama appealed the agency's decision, which was upheld on appeal. Agrama then filed suit.
Complaint issues: Exemption 7(A) - Interference with ongoing investigation, Litigation - Attorney's fees

DefendantINTERNAL REVENUE SERVICE
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
Complaint attachment 5
Complaint attachment 6
Complaint attachment 7
Complaint attachment 8
Complaint attachment 9
Complaint attachment 10
Complaint attachment 11
Complaint attachment 12
Opinion/Order [31]
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2016-04-221COMPLAINT against INTERNAL REVENUE SERVICE ( Filing fee $ 400 receipt number 0090-4497356) filed by JEHAN AGRAMA. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Civil Cover Sheet, # 9 Notice of Related Case, # 10 Summons to IRS, # 11 Summons to USA-DC, # 12 Summons to USAG)(Rizek, Christopher) Modified on 4/25/2016 (sth). (Entered: 04/22/2016)
2016-04-22Case Assigned to Judge Rosemary M. Collyer. (sth) (Entered: 04/25/2016)
2016-04-252SUMMONS (3) Issued Electronically as to INTERNAL REVENUE SERVICE, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Summons, # 2 Summons, # 3 Summons)(sth) (Entered: 04/25/2016)
2016-04-283MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Dennis L. Perez, :Firm- Hochman, Salkin, Rettig, Toscher & Perez, P.C., :Address- 9150 Wilshire Blvd., Suite 300, Beverly Hills, CA 90212. Phone No. - (310) 281-3240. Fax No. - (310) 859-1430 Email - perez@taxlitigator.com Filing fee $ 100, receipt number 0090-4504939. Fee Status: Fee Paid. by JEHAN AGRAMA (Attachments: # 1 Certification in Support)(Rizek, Christopher) (Entered: 04/28/2016)
2016-04-29MINUTE ORDER granting 3 Motion for Leave to Appear Pro Hac Vice. Dennis Perez may appear pro hac vice for Plaintiff. Signed by Judge Rosemary M. Collyer on 4/29/2016. (KD) (Entered: 04/29/2016)
2016-08-014RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 7/13/2016. Answer due for ALL FEDERAL DEFENDANTS by 8/12/2016. (Rizek, Christopher) (Entered: 08/01/2016)
2016-08-015RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed on United States Attorney General. Date of Service Upon United States Attorney General 07/13/2016. (Rizek, Christopher) (Entered: 08/01/2016)
2016-08-016RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed. INTERNAL REVENUE SERVICE served on 7/13/2016 (Rizek, Christopher) (Entered: 08/01/2016)
2016-08-127ANSWER to Complaint by INTERNAL REVENUE SERVICE.(Sasarak, Stephanie) (Entered: 08/12/2016)
2016-08-15MINUTE ORDER requiring the parties to file a joint proposed briefing schedule on dispositive motions no later than August 26, 2016 . Signed by Judge Rosemary M. Collyer on 8/15/2016. (lcrmc1) (Entered: 08/15/2016)
2016-08-15Set/Reset Deadlines/Hearings: Joint proposed briefing schedule due by 8/26/2016. (cdw) (Entered: 08/15/2016)
2016-08-268PROPOSED BRIEFING SCHEDULE re Order by INTERNAL REVENUE SERVICE. (Sasarak, Stephanie) (Entered: 08/26/2016)
2016-08-26MINUTE ORDER approving 8 Joint Proposed Briefing Schedule. The parties shall file a joint status report no later than September 16, 2016 . Signed by Judge Rosemary M. Collyer on 8/26/2016. (lcrmc1) (Entered: 08/26/2016)
2016-09-169Joint STATUS REPORT And Proposed Briefing Schedule by INTERNAL REVENUE SERVICE. (Sasarak, Stephanie) (Entered: 09/16/2016)
2016-09-16ORDER approving proposed briefing schedule. Defendant shall file its Motion for Summary Judgment no later than November 1, 2016. Plaintiff shall file her Opposition to Motion for Summary Judgment and Cross Motion for Summary Judgment no later than December 1, 2016. Defendant shall file its Reply in Support of Motion for Summary Judgment and Opposition to Cross Motion for Summary Judgment no later than December 15, 2016. Plaintiff shall file her Reply in Support of Cross Motion for Summary Judgment no later than December 30, 2016. Signed by Judge Rosemary M. Collyer on 9/16/2016. (DAS) (Entered: 09/16/2016)
2016-09-16Set/Reset Deadlines/Hearings: Summary Judgment motion due by 11/1/2016. Response to Motion for Summary Judgment due by 12/1/2016. Reply to Motion for Summary Judgment due by 12/15/2016. Cross Motion due by 12/1/2016. Response to Cross Motion due by 12/15/2016. Reply to Cross Motion due by 12/30/2016. (cdw) (Entered: 09/16/2016)
2016-11-0110MOTION for Summary Judgment by INTERNAL REVENUE SERVICE (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Affidavit Coen Declaration, # 4 Affidavit Lepore Declaration, # 5 Affidavit Valvardi Declaration, # 6 Text of Proposed Order)(Sasarak, Stephanie) (Entered: 11/01/2016)
2016-12-0111Memorandum in opposition to re 10 MOTION for Summary Judgment of the Internal Revenue Service filed by JEHAN AGRAMA. (Attachments: # 1 Declaration, # 2 Exhibit, # 3 Statement of Facts)(Perez, Dennis) (Entered: 12/01/2016)
2016-12-0112Cross MOTION for Summary Judgment by JEHAN AGRAMA (Attachments: # 1 Text of Proposed Order)(Perez, Dennis) (Entered: 12/01/2016)
2016-12-0113SEALED MOTION FOR LEAVE TO FILE DOCUMENT UNDER SEAL filed by JEHAN AGRAMA (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 1 of Declaration of Dennis L. Perez, # 2 Exhibit 3 of Declaration of Dennis L. Perez, # 3 Text of Proposed Order)(Perez, Dennis) (Entered: 12/01/2016)
2016-12-0114NOTICE that Exhibits 1 and 3 of the Perez Declaration are Lodged Under Seal by JEHAN AGRAMA (Perez, Dennis) (Entered: 12/01/2016)
2016-12-02MINUTE ORDER granting 13 Sealed Motion for Leave to File Document Under Seal. Signed by Judge Rosemary M. Collyer on 12/2/2016. (lcrmc1) (Entered: 12/02/2016)
2016-12-0515SEALED DOCUMENT (Exhibits 1 and 3) filed by JEHAN AGRAMA. (This document is SEALED and only available to authorized persons.) (Attachments: # 1 Exhibit 3 of Declaration of Dennis L. Perez)(znmw) (Entered: 12/05/2016)
2016-12-1316Unopposed MOTION for Extension of Time to File Response/Reply And Reset Deadlines by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Sasarak, Stephanie) (Entered: 12/13/2016)
2016-12-13MINUTE ORDER granting 16 Motion for Extension of Time to File Response/Reply. Defendant shall file its Reply in Support of Motion for Summary Judgment and Opposition to Cross Motion for Summary Judgment no later than December 22, 2016. Plaintiff shall file her Reply in Support of Cross Motion for Summary Judgment no later than January 9, 2017. Signed by Judge Rosemary M. Collyer on 12/13/16. (lcrmc1) (Entered: 12/13/2016)
2016-12-13Set/Reset Deadlines/Hearings: Defendant's reply to Motion for Summary Judgment due by 12/22/2016. Defendant's response to Cross Motion due by 12/22/2016. Plaintoff's reply to Cross Motion due by 1/9/2017. (cdw) (Entered: 12/14/2016)
2016-12-2217REPLY to opposition to motion re 10 MOTION for Summary Judgment filed by INTERNAL REVENUE SERVICE. (Attachments: # 1 Response to Plaintiff's Statement of Undisputed Material Facts)(Sasarak, Stephanie) (Entered: 12/22/2016)
2016-12-2218Memorandum in opposition to re 12 Cross MOTION for Summary Judgment filed by INTERNAL REVENUE SERVICE. (Attachments: # 1 Response to Plaintiff's Statement of Undisputed Material Facts)(Sasarak, Stephanie) (Entered: 12/22/2016)
2017-01-0619REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT filed by JEHAN AGRAMA. (Perez, Dennis) (Entered: 01/06/2017)
2017-01-1320MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Evan J. Davis, :Firm- Hochman, Salkin, Rettig, Toscher & Perez, P.C., :Address- 9150 Wilshire Blvd., Suite 300, Beverly Hills, CA 90212. Phone No. - (310) 281-3288. Fax No. - (310) 859-1430 Email - davis@taxlitigator.com Filing fee $ 100, receipt number 0090-4806675. Fee Status: Fee Paid. by JEHAN AGRAMA (Attachments: # 1 Certification in Support)(Rizek, Christopher) (Entered: 01/13/2017)
2017-01-17MINUTE ORDER granting 20 Motion for Leave to Appear Pro Hac Vice as to Attorney Evan J. Davis. Signed by Judge Rosemary M. Collyer on 1/17/2017. (lcrmc1) (Entered: 01/17/2017)
2017-02-1021MOTION to Amend/Correct Reply in Support of Plaintiff's Cross-Motion for Summary Judgment by JEHAN AGRAMA (Attachments: # 1 Declaration of Dennis L. Perez, # 2 Exhibit 5 of Dennis L. Perez Declaration)(Perez, Dennis) (Additional attachment(s) added on 2/13/2017: # 3 Amended Reply, # 4 Text of Proposed Order) (znmw). (Entered: 02/10/2017)
2017-02-1022ENTERED IN ERROR.....REPLY In Support of Plaintiff's Cross-Motion for Summary Judgment filed by JEHAN AGRAMA. (Attachments: # 1 Text of Proposed Order)(Perez, Dennis) Modified on 2/13/2017 (znmw). (Entered: 02/10/2017)
2017-02-13NOTICE OF ERROR re 22 Reply to Document; emailed to perez@taxlitigator.com, cc'd 6 associated attorneys -- The PDF file you docketed contained errors: 1. Leave to file not yet requested and/or granted, 2. ENTERED IN ERROR as a separate docket entry; the proposed amended reply will be added as an exhibit to the motion 21 and will be refiled when/if the motion is granted. (znmw, ) (Entered: 02/13/2017)
2017-02-2323Memorandum in opposition to re 21 MOTION to Amend/Correct Reply in Support of Plaintiff's Cross-Motion for Summary Judgment filed by INTERNAL REVENUE SERVICE. (Attachments: # 1 Exhibit)(Sasarak, Stephanie) (Entered: 02/23/2017)
2017-03-0224REPLY to opposition to motion re 21 MOTION to Amend/Correct Reply in Support of Plaintiff's Cross-Motion for Summary Judgment filed by JEHAN AGRAMA. (Perez, Dennis) (Entered: 03/02/2017)
2017-03-2825ORDER granting 21 Motion to Amend/Correct. The Clerk of the Court is hereby directed to file Plaintiffs Amended Motion [Dkt. 21-3], the Declaration of Dennis Perez in Support thereof [Dkt. 21-1], and Exhibit 5 attached to the Declaration of Dennis Perez [Dkt.21-2]. Signed by Judge Rosemary M. Collyer on 3/28/2017. (lcrmc1) (Entered: 03/28/2017)
2017-03-2826AMENDED REPLY to opposition to motion re 12 Cross MOTION for Summary Judgment filed by JEHAN AGRAMA. (Attachments: # 1 Declaration of Dennis L. Perez, # 2 Exhibit 5 of Dennis L. Perez Declaration)(znmw) (Entered: 03/29/2017)
2017-03-3127MOTION for Leave to File Documents for the Court's In Camera Review by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Sasarak, Stephanie) (Entered: 03/31/2017)
2017-04-0628Memorandum in opposition to re 27 MOTION for Leave to File Documents for the Court's In Camera Review filed by JEHAN AGRAMA. (Davis, Evan) (Entered: 04/06/2017)
2017-06-2329ORDER granting Defendant's 27 Motion for Leave to File Documents for the Court's In Camera Review. Defendant is further ordered to deliver to chambers for the Court's in camera review no more than one declaration and one addendum brief by July 14, 2017. Signed by Judge Rosemary M. Collyer on 6/23/2017. (lcrmc1) (Entered: 06/23/2017)
2017-06-23Set/Reset Deadlines/Hearings: Defendant's In-Camera Submission due by 7/14/2017. (cdw) (Entered: 06/26/2017)
2017-07-1330NOTICE of Compliance by INTERNAL REVENUE SERVICE re 29 Order on Motion for Leave to File, (Sasarak, Stephanie) (Entered: 07/13/2017)
2017-10-2031MEMORANDUM AND OPINION. Signed by Judge Rosemary M. Collyer on 10/20/2017. (lcrmc1) (Entered: 10/20/2017)
2017-10-2032ORDER granting Defendant's 10 Motion for Summary Judgment and denying Plaintiff's 12 Cross-Motion for Summary Judgment. Judgment is entered in favor of Defendant on all counts. This case is closed. Signed by Judge Rosemary M. Collyer on 10/20/2017. (lcrmc1) (Entered: 10/20/2017)
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by FOIA Project Staff